Mazars and the Compliance Institute are delighted to publish this follow-up to our first Individual Accountability Framework (IAF) readiness survey report in March 2022.
Our November 2022 report is based on 160 survey responses received. July and October 2022 have witnessed further developments in the legislative journey of the Central Bank (Individual Accountability Framework) Bill.
In July 2022, we saw the publication of the Central Bank (Individual Accountability Framework) Bill 2022 (the 'Bill'), which provided several enhancements to the July 2021 General Scheme (the 'General Scheme').
In October 2022, the Bill was further discussed at Second Stage in Dáil Éireann, and at the time of writing, the Bill is currently before Dáil Éireann (Third Stage).
The Bill follows a similar structure and focuses as the General Scheme, such that the Individual Accountability Framework (IAF) will consist of four key pillars, specifically:
The new Senior Accountability Executive Regime (SEAR).
New conduct standards for regulated firms, their management and staff.
Enhancements to the existing Fitness and Probity ('F&P') regime.
Enhanced Central Bank of Ireland (CBI) enforcement powers.
It has been five years since the GDPR came fully into force. We now have a good idea of how data protection will be interpreted and should be applied. We also understand that it's always a moving target with internal organisation changes, external guidance, sanctions, and judgement needing to be understood and addressed.
In a recent article for The Irish Compliance Quarterly, Kian Caulwell, Partner, Head of Financial Services Consulting at Mazars and a member of the Compliance Institute’s Consumer Protection Working Group outlines the opportunities and challenges of being a compliance officer in an early-stage firm.
The Central Bank (Individual Accountability Framework) Bill 2022 (the Bill) will ensure that conduct risk will remain a key risk that all regulated financial services firms (firms) must be able to demonstrate it is proactively managing and mitigating. In all likelihood, one of the key impacts of the Bill will be the elevation of conduct risk further up the Board’s risk agenda prioritisation in 2023 and beyond.